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Taxation of financial arrangements paper
Published on 13 Mar 13 by NATIONAL DIVISION, THE TAX INSTITUTE
This paper provides a progress report on the TOFA rules in Div 230 of the Tax Act which have substantially reshaped the way that many taxpayers have to recognise financial transactions for tax purposes.
Topics covered include:
- TOFA overview
- where the law is at now and current TOFA issues
- ATO compliance activities – focus areas of ATO review
- risk management
- was TOFA a good idea and what can be done to improve it?
Author profiles
Anthony Frost CTA
Tony Frost in his first, 34-year career was one of Australia’s leading corporate tax advisers. He was, and still is, a lawyer and a Chartered Accountant. His clients included BHP Billiton, Macquarie Bank, Westpac Banking Corporation and the Commonwealth Bank of Australia. Before joining Greenwoods in 2003, he had been a tax partner at PwC for seven years. Prior to that, Tony spent five years working in-house at Westpac Banking Corporation. Throughout his tax career, Tony was a regular speaker at TTI events. Tony finished his tax career in 2018, after being Managing Partner, for seven years, of tax advisory firm Greenwoods & Herbert Smith Freehills, one of Australia’s most lauded professional service firms. Since 2019, and after completing a Master of Science in Coaching Psychology degree at the University of Sydney, Tony has been having a second career as an executive coach, mentor, leadership consultant, facilitator and trainer. He holds a number of non-executive company directorships and is the non-executive Chairman of the Leadenhall Valuation Services group. Tony is a graduate of the Australian Institute of Company Directors and now teaches the AICD’s prestigious Company Directors’ Course. Tony is also the author of The Professional: A Playbook to Unleash Your Potential and Futureproof Your Success, Tony has been a proud member of The Tax Institute for about 40 years.
- Current at
06 July 2026
Andrew Hirst CTA
Andrew is a Partner and Head of Financial Services at Greenwoods & Herbert Smith Freehills. Andrew advises on a range of corporate and banking-related tax issues with a particular focus on financial and international transactions. Andrew has worked with Treasury and the ATO on various areas of tax reform that impact the financial services industry. - Current at 16 November 2021
This was presented at The 28th National Convention .
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